disadvantage client
positions. Trades of employees and family members will be monitored by
Jennifer Shufro,
Alkeon's Managing Director of Legal and Compliance (the "Compliance
Director"). In addition,
employees ... services
provided to Alkeon (all
gifts in excess of $100 must be reported to Jennifer Shufro, Alkeon's
Compliance Director). No
Alkeon employee may solicit gifts, and no cash gifts